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<br />-5- <br />Surface Water <br /> <br />7. No sample of water quality in the pond was contained in Exhibit 11 as <br />stated on page 2.04-18. <br />8. The data collected for surface water quality is not adequate to define <br />the water quality of Coal Gulch. At a minimum, samples should be <br />presented for water quality upstream and downstream of the proposed <br />mining operations over a consecutive twelve month period. These <br />samples should be collected on Coal Gulch itself, not on adjacent <br />streams. <br />9. No information was presented to identify seasonal variations in water <br />quality or quantity of Coal Gulch. A monitoring program for future <br />potential impacts should also be developed. <br />]0. Section 4.05.2 states that the pH of the pond was reported as being <br />less than 6.0 in Section 2.04.7 of the permit application. No such <br />information was found in this section. <br />11. The Division does not feel that there is any evidence to support the <br />applicant's reasoning in discussing the development of the low pN water <br />present in the pond. Furthermore, the Division feels that there is <br />significant potential for subsurface water to be causing the low pH. <br />The applicant should revise this and other appropriate sections of the <br />permit application to include a discussion of actual evidence to <br />support the statements made. <br />Alternative Water Supply <br />12. The requirements of this section of the regulations have not been <br />addressed. The conclusions drawn in this section of the permit can not <br />be substantiated. More information is required before the applicant <br />can be released from demonstrating that an alternative water supply is <br />available or necessary. <br />13. No map was submitted showing water supply intakes, irrigation ditches, <br />reservoirs and wells within a one mile minimum radius of the affected <br />area. No current users of surface water were identified. <br />Monitoring <br />14. Section 4.05.13 needs to be revised to reflect a surface and ground <br />water monitoring program for the life of mining. <br />Climatological Information - Rule 2.04.8 <br />1. The applicant should provide monthly averages for both temperature and <br />precipitation in Tables 4 and 3 respectively. The applicant should <br />also provide temperature range data and average velocity of prevailing <br />winds information. <br />